The CFPB has released the final list of Rural and Underserved Counties to be used in 2014. A separate list of Rural Counties was also included as properties located in these rural counties will be exempt from the second appraisal requirement (if otherwise applicable) under the new HPML appraisal requirements.
In addition to the HPML Escrow rule (already in effect) and the HPML Appraisal requirements, the Ability To Repay/Qualified Mortgage standards and High-Cost Mortgage rules also contain references to Rural and Underserved counties. We’ve seen recent changes and proposals as to how certain exemptions (based on this designation) will or may be impacted. We’ve also heard from the CFPB that they are going to take another look in the coming years at how “rural” and “underserved” have been defined for purposes of the exemptions.
It can be a LOT to take in. For now, you may want to take a look at the list to see if there are changes that may impact you. This should help you gain a better understanding of where you sit as we see more requirements finalized.
Diane joined Banker’s Compliance Consulting with over 10 years of compliance experience and over 15 years of experience within the financial industry. Diane is a Certified Regulatory Compliance Manager (CRCM) and has a Bachelor’s Degree in Sociology with a concentration in Criminal Justice. She is a graduate of the Schools of Banking Compliance School and has participated in various other training opportunities throughout her career. Diane understands firsthand the struggles banks face in building and maintaining successful compliance programs. Her experience and common sense approach to consumer compliance is a great asset to our clients.
Diane and her husband have two kids who keep them busy. She enjoys running and other sports and is a big Bugs Bunny fan! She’s a bit crazy in that she does enjoy reading some of these regulations and she’s a “crazy cat lady!” Her cat tales are hilarious!